heritance Digital’s Personal Data Protection Policy
This is the heritance Digital’s Personal Data Protection Policy for all users of our website.
This purpose of this Personal Data Protection Policy (“Policy”) is to allow you to have a better understanding of the processes involved in protecting your Personal Data in accordance with the Personal Data Protection Act 2012 (“PDPA”) by the Personal Data Protection Commission Singapore (“PDPC”). Please read this Policy so that you understand the purposes for which we collect, use, disclose or process your Personal Data.
In this Policy, (“we”, “us”, “our” or “HD”) refers to heritance Digital Pte Ltd.
By submitting information to us or signing up for any promotions, services or products offered by us, you agree and consent to HD collecting, using, disclosing and processing of your Personal Data amongst themselves, and disclosing such Personal Data to HD’s authorized service providers and relevant third parties in the manner set forth in this Policy.
This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of HD which we have engaged to collect, use, disclose or process for our purposes.
Under this policy, please be assured that your Personal Data shall only be used for HD’s businesses and services. Where necessary, we will require any person to whom we provide your Personal Data to agree to comply with our Personal Data Protection Policy.
We may also amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way HD uses your Personal Data or any changes to the laws and regulations applicable. We will make available the updated policy on our website and will only notify you of the changes where required by law to do so.
All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.
1. Personal Data
1.1. In this Policy, (“Personal Data”) means any data or information about you, whether true or not, from which you can be identified; or from that data and other information to which HD has or is likely to have access.
1.2. Personal Data we collect shall be used for HD’s businesses and services only.
1.3. Personal Data we collect and for what purpose will depend on the type of services provided to you and may include:
a. Full name, including aliases.
b. National Registration Identification Card number (“NRIC”).
c. Passport number and country of issue.
e. Family/beneficiary details.
f. Tax residency & Tax Identification Number.
g. Occupation information including the name of employer, position held, address of business and nature of employment.
h. Contact details including house phone number, mobile phone number, email address and mailing address; and
i. Any other Personal Data derived from any legal documentation including Insurance Policies, Letter of Administration, Grant of Probate, Power of Attorney, Birth Certificate and Death Certificate.
2. Collection of Personal Data
2.1. Personal Data is collected:
a. When you sign up to purchase our products and services from us.
b. When you register your interest with us to purchase our products and services.
c. When you attend our public talk and seminars.
d. When you visit our websites or social networking sites.
e. Pursuant to any transaction or enquiry or communication made with or to us.
f. From third-party sources such as credit reference agencies, fraud prevention agencies and publicly available sources of information.
3. Usage of Personal Data
3.1. We generally process the Personal Data collected for the following purposes;
a. For billing and financial purposes, including payments for HD services (and all transactions related thereto), accounting and tax.
b. For administrative purposes.
c. To comply with legal and statutory requirements.
d. For contact purposes.
e. For responding to your enquires.
f. To conduct research and statistical analysis.
3.2. We may use your Personal Data for marketing purposes, including:
a. Monitoring and improving our product and service offerings.
b. Providing you with regular communications relating to services provided by HD from time to time.
c. For direct marketing purposes.
d. Providing you with information and updates on products and services.
3.3. Such marketing messages may be sent to you in various modes including:
a. Electronic mail.
b. Direct mailers.
c. Short message service.
d. Telephone calls.
4. Disclosure and Sharing of Personal Data
4.1. To facilitate the purpose above and the provision of products and services to you, we may process, use and disclose your Personal Data to the following classes of third parties:
a. Related companies of HD.
b. Service providers (including those located overseas) providing services relating to the purposes for which the Personal Data is collected.
c. Our service providers, consultants, auditors and advisors on a need to know basis.
d. Your other professional advisers, subject to your approval.
e. Regulatory authorities and enforcement agencies.
f. Any court of law or any relevant party in connection with any claim or legal proceedings; and
g. Any person who is under a duty of confidentiality who has undertaken to keep such Personal Data confidential.
4.2. As HD adopts cloud-based solutions for our client administration, your Personal Data might be moved and stored in the cloud-based solutions with their servers located outside of Singapore. However, HD wishes to ensure you that your Personal Data are protected to a standard comparable to that under the PDPA, in the jurisdictions that they are transferred to.
5. How does HD protect your Personal Data
5.1. The security and protection of Personal Data are of utmost importance. In HD, we have internal policies and controls in place to ensure that Personal Data is prevented from unauthorised disclosure, use, alteration or destruction.
5.2. Your Personal Data is not accessible except by our trained staff and managers who will act honestly and proper in the performance of their duties.
5.3. Whenever applicable, we will also use encryption and other technologies that can assist in securing the Personal Data provided to us.
5.4. It is of utmost importance that your Personal Data is protected whenever they are transferred to a jurisdiction outside of Singapore. HD will ensure that the software we use is hosted on reputable cloud solutions providers such as Amazon Web Services and Microsoft Azure. In addition, we also ensure that the software has high-security features such as:
a. 256 bit SSL implemented for all web browser-based conversations;
b. 4 digit PIN required to access any mobile app;
c. Dual encryption of all documents stored on the platform for enhanced security;
d. Passwords are not stored on the system but managed through a token-based system.
6. How long will your Personal Data be kept for?
6.1. Your Personal Data will be retained for as long as necessary to fulfil the business or legal purposes we collected it for.
6.2. Once your business relationship with us has ended, or when retention is no longer necessary, we will securely delete or destroy your Personal Data in accordance with our data retention policy and applicable laws and regulations unless retention is required to satisfy legal or regulatory requirements.
7. Access and correction of Personal Data
7.1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below:
Data Protection Officer
You may also contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.
7.2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
7.3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
8. Withdrawing Your Consent
8.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided above.
8.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
8.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8.1 above.
8.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
9. Governing Law
9.1. This Policy shall be governed in all respects by the Laws of Singapore.